Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court reversed Defendant's conviction for two counts of aggravated sexual assault of a minor and two counts of risk of injury to a child, holding that the trial court improperly failed to order that certain material be turned over to the defense and that the error was not harmless beyond a reasonable doubt.On appeal, Defendant argued, among other things, that the trial court violated his Sixth Amendment right to confrontation by not ordering disclosure of the victims' psychiatric records to the defense. The Supreme Court agreed, holding that the trial court (1) committed harmful error by failing to order that exculpatory and relevant impeachment material contained in the victims' psychiatric records be turned over to the defense; (2) improperly precluded cross-examination of the mothers of the victims concerning their U visa applications; and (3) improperly instructed the jury. View "State v. Juan A. G.-P." on Justia Law

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The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress statements he had made during two separately recorded interrogations of him by police officers, holding that the trial court properly denied Defendant's motion to suppress.The two interrogations at issue occurred on the same day. As to the first interrogation, Defendant claimed that the police failed to advise him of his rights pursuant to Miranda v. Arizona, 384 U.S. 436 (1966). Defendant further claimed that the second interrogation was tainted by the alleged illegality of the first interrogation. The trial court denied the motion to suppress and, following a jury trial, convicted Defendant of manslaughter in the first degree with a firearm. The Supreme Court affirmed, holding (1) Miranda warnings were not required for the first interrogation because it was not custodial; and (2) the failure to provide the warnings did not taint the second interrogation. View "State v. Brandon" on Justia Law

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The Supreme Court affirmed the judgment of the habeas court denying Petitioner's petition for a writ of habeas corpus, holding that Petitioner failed to establish that he was entitled to relief.Petitioner was convicted of manslaughter in the first degree with a firearm, assault in the first degree, and criminal possession of a firearm. In his habeas petition, Petitioner argued that his trial counsel's concession of Petitioner's guilt to the manslaughter charge without Petitioner's prior approval violated his rights to effective assistance of counsel under Strickland v. Washington, 466 U.S. 668 (1984), and personal autonomy under McCoy v. Louisiana, __ U.S. __ (2018). The habeas court denied the petition, finding Petitioner's claims to be without merit. The Supreme Court affirmed, holding (1) the habeas court correctly determined that Petitioner's right to autonomy was not implicated under the facts of this case; and (2) Petitioner's second claim on appeal was unpreserved. View "Grant v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed the judgment of the trial court joining for trial, pursuant to Practice Book 41-19, sexual assault, risk of injury to a child, and strangulation charges with threatening and disorderly conduct charges, holding that the trial court did not err or abuse its discretion.Specifically, the Supreme Court held that the trial court did not abuse its discretion when it (1) joined the sexual assault cases and the threatening and disorderly conduct cases for trial; and (2) denied Defendant's request, as a remedy for the disclosure of his prior incarceration by one of the state’s witnesses, that he be allowed to testify about the nonsexual nature of his prior felony convictions without opening the door to being asked on cross-examination about the nature of those convictions. View "State v. James A." on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed in part the judgment of the appellate court affirming Defendant's conviction of sexual assault in the first degree, risk of injury to a child, and conspiracy to commit risk of injury to a child, holding that the case must be remanded to the trial court for a new trial on the sexual assault count.On appeal from his convictions, Defendant argued that each count was duplicitous because each count charged him with a single violation of the underlying statute when the evidence established multiple, separate incidents of conduct and, consequently, the court's failure to either grant his request for a bill of particulars or a specific unanimity instruction violated his constitutional right to jury unanimity. The Supreme Court reversed in part, holding (1) count two, charging the defendant with a single violation of Conn. Stat. Ann. § 53-21 (a) (2), was not duplicitous, and thus the trial court’s failure to grant the defendant’s request for a specific unanimity instruction or a bill of particulars as to that count did not violate his constitutional right to jury unanimity; and (2) Defendant was not entitled to reversal of his remaining convictions. View "State v. Joseph V." on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the appellate court upholding Defendant's conviction of five counts of risk of injury to a child, holding that the trial court properly declined to give the jury a specific unanimity instructions as to counts one, five, and six.During trial, defense counsel requested that the court provide a specific unanimity instruction as to the counts at issue on appeal because the evidence showed there were discrete incidents, not a continuing course of conduct. The court declined to give the instruction. On appeal, Defendant argued that counts one, five, and six were duplicitous because each count charged him with a single violation of Conn. Rev. Stat. 53-21(a)(2). The Supreme Court affirmed, holding that, from the evidence, the jury reasonably could have found that Defendant's criminal acts constituted a single criminal episode and thus did not constitute multiple, separate incidents of conduct under the applicable test. View "State v. Douglas C." on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the trial court with respect to the count of risk of injury to a child pertaining to one of the complainants and otherwise affirmed Defendant's conviction of several counts of sexual assault, holding that the evidence presented at trial was sufficient to support the remaining convictions.Defendant was convicted of several counts of attempt to commit sexual assault in the first degree, sexual assault in the first degree, sexual assault in the second degree, and risk of injury to a child. On appeal, Defendant argued, among other things, that the evidence presented at trial was insufficient to support his conviction on certain counts. The Supreme Court reversed in part, holding (1) the evidence was insufficient to support Defendant's conviction for risk of injury to a child; and (2) the prosecutor's use of Defendant's prior misconduct was improper, but the jury's verdict would not have been different in the absence of that comment. View "State v. Gary S." on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder, with robbery in the third degree as the predicate felony and carrying a pistol or revolver without a permit, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the prosecutor committed improprieties during closing argument by arguing facts that were not in evidence and by making inferences that were unsupported by the evidence. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the conviction of felony murder with the predicate felony of third-degree robbery; and (2) the prosecutor did not engage in improprieties during closing argument that deprived Defendant of his due process right to a fair trial. View "State v. Brown" on Justia Law

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The Supreme Court granted in part Defendant's petition for review of the trial court's denial of his motion for modification of the $20 million bond that was set in connection with murder charges against him, holding that remand was required for the trial court to consider Petitioner's request for a ten percent bail option pursuant to Practice Book 38-8.In his petition, Defendant argued that the bail amount was unreasonably high and that the trial court erroneously concluded that it lacked the authority to grant Defendant's request for a ten percent cash option. The Supreme Court remanded the case, holding (1) given the extraordinary flight risk and public safety considerations presented in this case, the trial court did not abuse its discretion in setting the bond amount at $20 million; and (2) the trial judge incorrectly concluded that he lacked discretion to offer Defendant a ten percent cash bail option under Practice Book 38-8. View "State v. Pan" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed in part and reversed in part Defendant's conviction for one count of arson in the first degree, eight counts of reckless endangerment in the first degree, and four counts of risk of injury to a child, holding that the trial court committed reversible error by applying incorrect and convincing Defendant under a provision he was not formally charged with violating.On appeal, Defendant raised three claims of error relating to his conviction on the counts alleging risk of injury to a child. The Supreme Court reversed the conviction in part, holding (1) this Court's reading of State v. Schriver, 542 A.2d 686 (Conn. 1988), and its progeny leads it to reject Defendant's first two claims on this record; and (2) the trial court committed reversible error by finding Defendant guilty of risk of injury to a child based on its application of the elements of the situation prong rather than of the act prong, as originally charged. View "State v. Ares" on Justia Law

Posted in: Criminal Law